Summary and Commentary on RRP Changes, July 2011
EPA finalized the changes to the Lead Renovation, Repair and Painting Rule.
Here is a quick summary on the changes that affect Renovators:
1. Vertical containments (i.e. plastic sheeting) are required when working within 10 feet of property line. The hope is to avoid contaminating the neighbors space.
2. HEPA shrouds or containment systems req’d on power equipment (ex. drills, sanders) at point of generation. These can often be purchased with the equipment or from and aftermarket distributor. The idea is attach a HEPA vac hose to the “head” of the equipment.
3. Dust testing can be conducted in lieu of the Cleaning Verification. Testing makes sense for both the contractor, who will know that the work was completed without any lead dust residue, and the occupants, who can be confident that they’re living in a lead safe environment. EEA offers the Dust Sampling Technician Certification. Contact UNYSE about “do it yourself” lead wipe sampling kits.
4. Paint chips can be collected to “rebut the presumption” of lead based paint instead of relying on the chemical test kits. UNYSE Labs provides National Lead Laboratory Approval Program (NLLAP) analysis of paint samples.
5. Prior training (i.e. lead safe work practices, abatment worker/supervisor) can only be used to qualify for Renovator refresher training until Oct 4, 2011. After that anyone who has completed LSWP or abatement training will have to attend the day long Renovator initial. Check our website for dates of refresher and initial Renovator training.
Here’s a couple new administrative requirements that don’t impact Renovators directly but may be of interest as the process evolves, especially in New York.
1. An EPA approved principal instructor must be present at all EPA accredited Renovator, Worker, Supervisor, Inspector and Risk Assessor courses. The hope here is to maintain the quality of the training. EEA has a full schedule of lead certification courses taught by principal instructors.
2. States that operate lead programs must be at least as stringent as the EPA program. This includes fine amounts and violations. EPA’s Enforcement Guidelines provides detail on the Federal level.
These changes and requirements take effect October 4th, 2011. We have already integrated discussion and hands-on dedicated to the changes.
We’ll continue to update on changes as they occur. Let us know how things are going on the job.